BRYAN, Circuit Judge.
The Beacon Refining Company, for the years 1920, 1921, and 1922, filed returns of its income and excess profit taxes as a trust. The Commissioner of Internal Revenue determined that the taxpayer was an association, and as such was taxable as a corporation under the Revenue Acts of 1918 and 1921. 40 Stat. 1057; 42 Stat. 227. Accordingly, he rejected its returns and required payment of additional taxes, which were collected by appellee, collector...
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